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Understanding Annual Reporting Obligations for VOC Rules in Oil & Natural Gas Sources

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On December 10, 2022, Pennsylvania introduced regulations regarding the control of VOC (Volatile Organic Compounds) emissions from both unconventional and conventional oil and natural gas sources. These regulations, detailed in 25 Pa. Code §§ 129.121-130 and 25 Pa. Code §§ 129.131-140, require businesses to submit annual reports containing specific compliance information.

When is the Report Due?

The initial annual report submission was due on December 10, 2023; however, DEP suspended enforcement of the initial annual report submission until June 1, 2024.  Thus, the deadline for the first annual report is now June 1, 2024. Learn more about the enforcement suspension in Volume 54 Number 4 of the Pennsylvania Bulletin.

How to Report:

The Pennsylvania Department of Environmental Protection (DEP) has created Excel spreadsheet templates to make reporting easier for owners and operators. These templates are available for Unconventional Oil & Gas and Conventional Oil & Gas sources. They break down reporting requirements into manageable sections. While using the template is optional, it is designed to help your small business comply with the regulations. If you prefer not to use the template, DEP is requesting that you still submit your report in Excel format.

How to Submit:

When you’re ready to submit your annual report, use DEP’s Public Upload System. Ensure your report is in spreadsheet format, preferably Excel. Choose “Air Quality Report or Miscellaneous Submission (No Payment)” as your submission type and “Other” as the request type. Specify the County and Municipality for each site covered by the Annual Report. Lastly, include either “129.130 Annual Report” or “129.140 Annual Report” in the Submission Notes Section.

Additional Resources:

For additional guidance on the submission process, refer to the public upload guide (PDF) provided by DEP.

Remember, these reports help in tracking and managing emissions, ensuring environmental compliance for your small business. If you are a small business and have any questions or need further assistance, please do not hesitate to contact EMAP.

Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC.  He holds over 15 years of experience in environmental compliance, environmental policy, and program management.  He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.